Regulatory Update: Minister of Trade Regulation No. 19 of 2026 on the Implementation of Trade Through Electronic Systems
by Setyawati Fitrianggraeni and Tiara Amanda Putri
Overview
Minister of Trade Regulation No. 19 of 2026 was issued to replace Minister of Trade Regulation No. 31 of 2023, aligning the regulatory framework with technological developments and the rapid growth of e-commerce in Indonesia.(1) This regulation responds to key challenges in the digital ecosystem, including personal data protection, unfair business practices, and the need for greater transaction certainty for consumers and businesses.(2) Through this regulation, the Government categorizes the e-commerce ecosystem into three main groups: sellers, e-commerce platform operators, and consumers, to clarify their respective roles, rights, and obligations within the digital trade framework.(3)
The implementation of this regulation specifically aims to enhance the competitiveness of domestic products, improve compliance with business licensing requirements, and strengthen the empowerment of Micro and Small Enterprises (MSEs).(1) In addition to strengthening legal compliance, this regulation serves as a tool to address various challenges in the digital ecosystem, including the risk of personal data misuse, unfair business practices, logistical challenges, and low levels of consumer legal awareness.(2) Through collaboration between platforms and the Government, this regulation promotes a fair, secure, and sustainable digital trade ecosystem in Indonesia.
Key Highlights
- Transparency of PMSE Fees and Written Agreements
PPMSE operators are required disclose all fees charged to merchants in writing transparently. This requirement applies to marketplace platforms, online classified ads, daily deals, social commerce, ride-hailing services, and online travel agents. All fees must be communicated in clear and understandable language and set out in a written agreement or electronic contract that can be downloaded by both parties. Platforms are required to inform merchants of any changes to fees or contractual terms in advance and obtain their approval. Any written objections submitted by merchants must be addressed within 14 business days.(1)
- Prioritization of Domestic Products and Dedicated Promotional Space
The regulation requires PMSE business actors to support government efforts to increase the use and competitiveness of domestically produced goods. The requirement applies to all PMSE business actors, both domestic and foreign, as well as MSEs. elPlatforms must provide dedicated promotional space for local products and ensure that search and recommendation systems prioritize domestic. The regulation also encourages platforms to offer incentives for MSEs marketing domestically produced goods, including discounts on promotional, advertising, and shipping fees, particularly during national and religious holiday periods. products by displaying them in top positions, including at least the first row of the first page.(1)
- Business Legality and NIB Verification
The regulation reinforces the requirement for all merchants operating on digital platforms to obtain a Business Identification Number or Nomor Identitas Bisnis (NIB). The obligation applies to domestic and foreign merchants, while platform operators are responsible for verifying compliance. Platforms must reject registrations from new merchants that do not hold a valid NIB in the trade sector and provide features that allow merchants to connect directly to the OSS system. The OSS system is an integrated electronic system for business licensing administered by the OSS institution for risk-based business licensing services. Existing merchants are granted a transition period of up to 18 months to fulfill this requirement.(1)
- Cross-Border PMSE and Foreign Representative Office Requirements
The regulation introduces specific requirements for cross-border e-commerce transactions and the legal presence of foreign platforms in Indonesia. The provisions apply to foreign merchants and foreign PMSE operators that meet certain transaction or traffic thresholds, including a minimum of 1,000 transactions per year. Under the regulation, finished goods imported and sold directly to Indonesian consumers are subject to a minimum FOB value of USD 100 per unit. Foreign platforms are also required to appoint a PMSE Representative Office (KP3A Bidang PMSE) in Indonesia to handle consumer protection matters and dispute resolution.(1)
References
1. Ministry of Trade of the Republic of Indonesia Regulation No. 19 of 2026 on the Implementation of Trade Through Electronic Systems.
2. Iskandar SA. Perkembangan E-Commerce di Indonesia: Regulasi dan Tantangannya. Media Hukum Indonesia (MHI) [Internet]. 2025 Oct;3(4):98–101. Available from: https://ojs.daarulhuda.or.id/index.php/MHI/article/view/2375/2527
3. CNN Indonesia [Internet]. 2026. Aturan E-Commerce Resmi Berlaku, Apa yang Berubah? Available from: https://www.cnnindonesia.com/ekonomi/20260609065926-92-1366880/aturan-e-commerce-resmi-berlaku-apa-yang-berubah
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